Mynydd Llansadwrn Action Group

Help Protect our Welsh Mountain Landscapes

Comments from Mynydd Llansadwrn Action Group

on

Wind Farm Development in the Brechfa Forest Area – A Discussion Paper

(Each comment is related to the appropriate paragraph in the Discussion paper)

1.1       To ensure that wind farm development in the Brechfa Forest area has due regard to the public interest….

  As part of the ‘discussion’, the planning department needs to explain what it means by ‘public interest’, what guarantees it can give that the public interest is in fact being ‘regarded’, and the measures it plans to put in place to safeguard the public interest.

  1.1    For the purposes of this Guidance the Brechfa Forest area is as defined on Map One.

  Map One includes an expanded area that encompasses and extends the original Strategic Search Area (SSA) as outlined in TAN8. However, the ARUP report has identified certain areas within the SSA that it considers suitable for wind farm development. It is unclear whether the subsequent discussion of the ‘ Brechfa Forest area’ throughout this document is referring to the new expanded area, the original SSA, or the areas identified in the ARUP report.

  It is important to note that, even if wind farm development were to be restricted to the areas identified in the ARUP report, the consequences will extend far beyond these areas. The visual intrusion of wind turbines will have a detrimental effect on the landscape and all those activities and related small businesses that rely on the scenic value of the area to attract visitors. Turbines will affect property values and residents’ quality of life. Because the effects of wind farm development are not restricted to the immediate vicinity of the turbines, it is necessary to consider the implications for the whole of the Brechfa Forest area and beyond.

  2.2       Wind farm development is expected to have a major impact in an area in which built development, hitherto, had a relatively low impact. The change is comparable to the major change to the area brought about by large scale conifer afforestation following the formation of the Forestry Commission in 1919. This Guidance seeks to minimise the impact of wind farm development and also suggest ways in which the impact can be offset or compensated for.

  The visual and ecological impact of conifer afforestation, even when the trees were non-native and planted in straight rows, cannot be compared with the introduction of 400-foot industrial machines with concrete bases and all their ancillary developments into the Brechfa Forest . It is difficult to envision what measures could possibly ‘offset’ this unprecedented intrusion into an unspoilt landscape.

  Conifer afforestation was a response to a critical need during the First World War for wooden pit props to keep the coal mines going. The aim was to establish a timber source as quickly and cheaply as possible. The main beneficiary of this planting programme was not the British public but private companies who could claim planting grants and substantial tax relief. It is now generally accepted that conifer afforestation inflicted great damage on wildlife and fragile ecological systems, particularly peat bogs. But the programme did not end until 1988 when Nigel Lawson scrapped forestry tax relief.

  It seems we are witnessing the same scenario with wind turbines. The main beneficiaries are private developers who benefit from subsidies in the form of Renewable Obligation Certificates. There is growing evidence that wind turbines inflict great damage on wildlife and fragile ecological systems, particularly peat bogs. Without substantial subsidies from the government, the rush to build wind farms would come to a grinding halt.

  Is the County Council in danger of facilitating an ecological, financial and public relations fiasco on an even greater scale than conifer afforestation proved to be?

  3.1       Wind turbine technology has evolved rapidly over the last twenty years and may now be considered proven technology for feeding electricity into the national grid.

  There are many well-documented problems with wind turbine technology. Cefn Croes, opened in June 2005, is a example of poor performance. According to the Cefn Croes monitoring group (see www.cefncroes.org.uk), none of the turbines were turning in August 2006 and were also idle in late-June and early-July because of mechanical failure. The average output at Cefn Croes from March to September 2005 was 14 MW, which is 24% of its installed capacity of 58.5 MW.

According to the monitoring group, Cefn Croes has actually become a carbon emitter because of the diesel generator operating at the substation and the sports vehicles that now use the new road network. But even more seriously, the dead peat at the site continues to emit its stored carbon dioxide and methane as it dries out.

Wind power has been in operation long enough for reliable data to be collected on its performance. This data calls into question some of the claims made by wind farm developers and the assumptions made by government planners.

  For example, a recent report (The Wind Power Report ED 3 2006) published by ABS Energy Research, an independent energy market research company, highlights new authoritative evidence that shows how wind power actually works, as opposed to what is being claimed. Here are some of the key findings cited in their report:

·     There is a mismatch of supply and demand. During periods of high pressure weather systems that bring cold winters and hot summers, wind speeds are at low levels but demand is at its highest. In other words, when demand is highest, wind power makes its minimum contribution.

·        Because of the variability of wind power, back-up fossil fuel plants must be operated at low load to maintain system reliability. Evidence shows that switching base load fossil fuel plants on and off to balance a system produces higher carbon emissions than continuous operation. So the backup required for wind is a higher than expected source of emissions.

·        Each country mentioned in the ABS report has experienced extreme difficulties in balancing the grid. During times of maximum feed-in from wind turbines, regional grids become heavily overloaded. Germany has found that it will need a further 2,700 km of costly high voltage transmission lines to accommodate its new wind capacity built in remote areas.

·        Wind power capacity in Germany is expected to reach 48 GW by 2020; however, this wind energy is so intermittent and unreliable that it is equivalent to only 2 GW of stable fossil fuel capacity.

·        In Denmark , during 2004, wind accounted for 20% of total electricity production but supplied only 6% of consumption. This happened because wind farms produced a surplus at periods of lowest demand. Denmark exported 84% of its wind-generated electricity to Norway , at a financial loss. Because the Norwegian electricity system uses carbon-free hydro power, the effect of emission reduction from Danish wind farms was nullified.

The ABS study gave this advice: ‘Wind power has been promoted for politico/environmental reasons and wind developers have benefited from substantial subsidies, leading to exaggerated claims. A reality check is needed.’

To ignore this growing body of evidence and to persist in describing wind power as a ‘proven technology’ is misleading the Council and the people of Carmarthenshire as to the true capacity of wind power to deliver a reliable source of electricity and to reduce carbon dioxide emissions.

4.1    The Brechfa Forest Area … is sparsely-populated and contains few settlements, which are sited mainly around the periphery of the Area.  Brechfa and Gwernogle are the main exceptions.

What is meant by ‘sparsely populated’? What is the exact population of the area that is being referred to in the above statement?

In addition to Brechfa and Gwernogle, the area outlined on Map One includes Abergorlech, Llansawel, Rydcymerau, Llanybydder, Llandysul, Llanllwni, Pencader, Alltwallis, Llanpumsaint, parts of Llanfynydd and Talley, as well as many smaller villages and hamlets. These communities will be directly affected by a wind farm sited anywhere in the Brechfa Forest . The environmental, economic and social consequences of a wind farm extend far beyond the construction site.

5.1       Wind farm development on the scale anticipated will have a major impact on the landscape character of the Brechfa Forest Area.

5.4       Wind farm development is likely to affect timber production, wildlife habitats and tourism and recreation industries dependant on certain scenic qualities. 

We would like the planning department to describe in more detail the nature of these major impacts and how they will affect the Brechfa Forest area.

The anticipated impacts are presumably negative. It is hard to envisage how wind farms will be beneficial to tourism, recreation industries, landscape character, property values, timber production, wildlife habitats, or residents’ quality of life.

How many more aspects of the economy, the environment and quality of life have to be negatively affected before the planning department considers saying no to this kind of industrial development in the Brechfa Forest ?

6.3       Welsh Assembly Government policy, which identifies the Brechfa Forest Area for major wind farm development in the period up to 2010, provides a justification for allowing local planning policies to be over-ridden in the wider public interest.

In this statement, the planning department is making an unsubstantiated assumption about the merits of wind power i.e. wind farm developments serve the wider public interest. The discussion paper does not specify the nature of this ‘wider public interest’; it assumes that because the Welsh Assembly in its TAN8 document has decreed that wind power serves the public interest, it must be so.

This assumption – that wind farms serve the wider public interest – has not been proven. Neither the Welsh Assembly nor the planning department have supplied any supporting statistical data, nor have they indicated the sources of information they are using to make their claims for the benefits of wind power.

On the other hand, there is a great deal of evidence that wind farms do not serve the public interest because they are an unreliable and intermittent source of electricity and they do little – if anything – to reduce carbon emissions. The stated aim of wind power development is to reduce our dependency on fossil fuel power plants. But wind farms do not achieve this aim because of the relatively low output and their need for dedicated backup. As Dr M Legerton admitted in his submission to the House of Commons Welsh Affairs Committee, ‘wind power has not replaced any fossil fuel plants’ (Energy in Wales, 2006, page 54, para 174).

The Energy in Wales report, published in July 2006 by the House of Commons Welsh Affairs Committee, has this to say about the public’s right to a satisfactory explanation on the merits of wind energy:

With the significant expansion of wind farms in Wales, the Welsh public is entitled to be given an objective assessment of its contribution to electricity supply in Wales (page 55, para 176).

The report goes on to say…

… It is unfair to dismiss all opposition to wind energy as nimbyism, without understanding the valid concerns that Wales is being overly populated by wind farms for what those opponents perceive as marginal benefit, set against the possible threat to leisure and tourist industries (page 59, para 195).

As part of an informed ‘discussion’, the planning department needs to provide the following statistics to justify its claims for wind power:

• The actual load, or capacity, factor of all wind turbines in Wales during 2005 compared to their rated load factor.
• The annual net CO₂ emission savings, using DTI figures, achieved by existing turbines in Wales based on actual output, not rated capacity.
• The projected CO₂ emission savings (using DTI not developer figures) from estimated actual output of the 90 MW of installed capacity planned for the Brechfa Forest .
• The percentage the above amount represents in relation to the national and global CO₂ emission output.
• The anticipated amount of CO₂ emissions from fossil fuel backup needed to stabilise output from wind turbines planned for the Brechfa Forest .
• The estimated CO₂ emission output during wind farm construction, e.g. road building, transport of materials, tree felling, peat bog destruction, etc., in the Brechfa Forest .
• The estimated number of acres of peat bog that will be destroyed by the construction of 90 MW of wind turbines in the Brechfa Forest . What this represents in terms of loss of carbon sink (peat bogs store three times as much carbon as is held in tropical rain forests). An estimate of the amount of CO₂ that will be released as these peat bogs dry up.
• The estimated number of acres of trees to be felled to make way for wind farm construction and what this represents in terms of loss of carbon sink.
• How the net CO₂ emission savings, taking into account the emission output during construction and from backup, compares with other measures such as energy efficiency, demand reduction, other renewable energy initiatives.

The Mynydd Llansadwrn Group expects the planning department, as part of this democratic discussion process, to address these points and provide us with accurate and unbiased information – i.e. information based on reliable, independent sources other than wind farm developers or their lobbying body, the British Wind Energy Association, who have a financial interest in promoting the benefits of wind power.

Until the planning department provides accurate unbiased data, it cannot, with any authority, promote the benefits of wind power – either as a reliable source of electricity or as a useful tool in reducing CO₂ emissions.

Climate change is a very real and imminent threat that requires effective responses. If wind farms are not an effective response, then pursuing this policy is irresponsible because it directs human ingenuity, endeavour and funding away from strategies that could be effective and have a chance of saving us and future generations from climatic disaster.

7.1       Carmarthenshire County Council has major roles to play as local planning authority, local highway authority and environmental health authority. In addition it is a lead partner for biodiversity action, coordinates and promotes tourism and recreation, and has an overall remit to safeguard the economic and social well being of communities in Carmarthenshire.

This statement reveals an obvious conflict of interests. On the one hand, the Carmarthenshire County Council and the planning office have a legal obligation to serve the best interests of the people of Carmarthenshire and to protect the local environment. But, on the other hand, the planning department has taken on the role of facilitating, at the behest of the Welsh Assembly and wind farm developers, industrial development in the Carmarthenshire countryside – a type of development that in any other circumstances would not be permitted because it seriously contravenes local planning policy. The planning department is asking Councillors to endorse this facilitating role.

The planning department has cited TAN8 as justification for its stance on this issue. It also relies on the wind farm developers to provide the technical information to support their planning applications. However, developers’ evidence is highly questionable. Our group and others have challenged the figures cited by the developers in their Blaengwen wind farm application. We argued that the developers had greatly overstated their claims for CO₂ emission savings and number of houses to be supplied by basing their calculation on figures that were inconsistent with those accept by the Department of Trade and Industry and the Carbon Trust. Nevertheless, the planning department accepted the developers’ estimates and recommended approval of the application. 

The discussion paper assumes that TAN8 forces the Council’s hand, that it must comply with Welsh Assembly policy on renewable energy. But TAN8 is a guideline only; it is not legislation. The County Council has no moral or legal obligation to follow the policy directives as set out in TAN8. However, the Council does have a moral and legal obligation to protect the rights and interests of the people of Carmarthenshire.

The House of Commons Welsh Affairs Committee report, Energy in Wales, has called into question the democratic validity of the TAN8 policy guideline:

When these two procedures [TAN8 and the Electricity Act] are combined, they leave little – if any – opportunity for local residents in Wales to mount a defence against applications for large wind farms in their locality. Not only is this deeply frustrating, it also undermines the democratic accountability that underpins decision-making in this policy area. We recommend that the Government review this position as a matter of urgency in order to give fair access to the decision-making process for individuals affected by large-scale wind farms in Wales (page 47, para 150).

The democratic process and the rights and interests of the people of Carmarthenshire should be the first consideration of the County Council, not the implementation of what is being recognised as a flawed energy policy document.

9.1 An important principle which is related to a number of ideas in this discussion paper, and which could be endorsed by planning policy is described here as the offsetting principle. 

It is interesting to note that this section of the paper discusses compensation for, or the ‘off-setting’ of, environmental damage only. There is no discussion of compensation for loss of quality of life or loss to property values.

Nor is there any recognition of the well-documented health problems associated with the low-frequency sound emitted by wind turbines. Some people living close to the Blaen Bowi wind farm, for instance, have experienced health problems since the turbines were built near their homes. These health concerns have been reported to the Council’s planning department. Current research into the area of low-frequency vibrations reveals increasing incidences of ill-effects from wind turbines. It is possible that health issues may, in the future, become grounds for compensation claims against local councils.

We feel it is futile on our part to discuss compensation, or landscape ‘off-sets’ or any other inducements that are aimed to soften the blow. In our view, there is no form of recompense that can possibly compensate for the damage that the Council will be inflicting on the local population if it allows this type of development to go ahead.

The Mynydd Llansadwrn Action Group is fundamentally opposed to the whole notion of wind farm development in the Brechfa Forest area.

 

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